Rafael Tena Castro

Rafael Tena Castro is the founding partner of Tena Abogados, S.C. and has nearly 20 years of professional experience advising and representing clients in tax, administrative, social security, and constitutional law. He is widely recognized for his ability to handle both contentious and non-contentious matters, with particular strength in complex tax litigation and high-level advisory work.

Rafael regularly advises national and international companies operating in Mexico, as well as Mexican businesses with cross-border operations. His practice includes representing clients in tax audits, conclusive agreements, and non-contentious proceedings before tax authorities, as well as successfully acting in high-stakes disputes before federal and local courts.

Rafael Tena Castro has built an impressive career advising both national and international companies operating in Mexico, as well as Mexican companies expanding abroad. His expertise spans tax audits, conclusive agreements, and various non-contentious proceedings before tax authorities. Additionally, Rafael has successfully represented clients in complex tax litigation cases before federal and local courts.

Before founding Tena Abogados, S.C., Rafael served as a partner at Acedo Santamarina, S.C., where he established the firm’s tax department and led it for over a decade. His earlier roles include serving as a senior associate in the tax area at Barrera, Siqueiros y Torres Landa, S.C. (now Hogan Lovells), and working with Ojeda & Asali, S.C. (now Bufete Asali, S.C.), where he gained valuable experience in civil, commercial, and administrative litigation.

Rafael is actively engaged in the legal community as a member of the Tax Law Commission of the Mexican Bar Association, A.C.

Rafael Tena Castro is the author of numerous articles and book chapters published in specialized national and international legal publications, with a particular focus on tax and constitutional law.

Among his principal academic contributions, Rafael coordinated and co-authored “El juicio de amparo en materia fiscal”, published by Tirant lo Blanch, which examines tax-related amparo proceedings in Mexico. In 2024, Tirant lo Blanch published the second edition of the book, which Rafael again coordinated and co-authored, incorporating recent developments in tax law and judicial interpretation. The second edition was presented at the International Book Fair at the Palacio de Minería in Mexico City and at the Guadalajara International Book Fair.

Rafael has also contributed to discussions on tax and economic policy through other publications. He authored the article “Será deuda” for El Economista, addressing Mexico’s economic outlook and fiscal policy challenges.

Together with Ricardo Jiram Caro Rocha, Rafael co-authored the scholarly article “The amparo proceeding provided for in section VII of Article 28 of the Constitution and its distinction with the amparo proceeding provided for in Articles 103 and 107 of the Constitution”, published in Issue 16 of the Jurídica Ibero journal.

In September 2025, Rafael presented on “Tax Valuation of Intangible Assets” in a virtual seminar organized by Tirant lo Blanch. He is also a frequent guest commentator on Meganoticias MX, where he discusses tax, financial, and legal developments.

Rafael and his team have swiftly positioned the firm as a trusted legal partner for a diverse client base, including multinational corporations, small and medium-sized enterprises (SMEs), high-net-worth individuals, and industry associations.

While most clients and matters remain confidential due to their sensitive nature, some of TENA Abogados’ most notable clients include:

• Garay Componentes Tubulares, S.A. de C.V.

• Los Reyes Industrial, S.A. de C.V.

• Rendimientos y Productos Inmobiliarios, S.A. de C.V.

• Grupo Inmobiliario Valru, S.A. de C.V.

• Kiddmex Servicios Globales, S. de R.L. de C.V. (KIDDE)

• Personal de Ventas y Servicios Industriales, S.A. de C.V.

• Grupo SOMAR.

• Atemporal, S.A. de C.V.

• Consorcio Inmobiliario Santa Fe, S.C.

• Química y Farmacia, S.A. de C.V. (QUIFA)

• F&S México Corporation, S. de R.L. de C.V.

• Servicios de Gestión LLYC, S. de R.L. de C.V. (LLORENTE & CUENCA)

• L’Oréal México (L´ORÉAL)

• Pimienta Films, S.A. de C.V.

Below is a selection of matters in which Rafael Tena acted as lead lawyer over the past year:

- Tax Audit Defense for High-net-worth Individual

Led the response and legal strategy for a high-net-worth individual facing a significant tax audit by the Mexican Tax Administration Service. The case addressed complex legal concepts like the materiality and indispensability of transactions, including the filing of a Conclusive Agreement request before the Taxpayer Defense Attorney’s Office.

- VAT Refund Disputes:

o Successfully challenged a ruling denying a VAT refund for Garay Componentes Tubulares, S.A. de C.V., securing a favorable ruling from the Seventeenth Collegiate Court in Administrative Matters, setting a significant precedent on transaction materiality.

o Obtained a favorable resolution from the Fourteenth Metropolitan Regional Chamber for the client’s VAT refund claim, reinforcing legal principles of transaction materiality and supplier dealings.

o Secured a favorable ruling from the Eighth Metropolitan Regional Chamber, confirming the client’s entitlement to a VAT refund and clarifying key tax provisions.

o Achieved recognition of VAT refund rights from the Seventh Metropolitan Regional Chamber, focusing on operational materiality within the client’s supplier relationships.

o Represented the client before the Twenty-First Collegiate Court, successfully ensuring the company’s VAT refund entitlement under Mexican Federal Tax Code provisions.

o Ongoing representation in securing VAT refunds for Garay Componentes Tubulares, S.A. de C.V., emphasizing compliance and operational materiality.

- Cross-border VAT Refund Strategy

Advised on VAT credit refund processes for transactions between Mexico and Spain, ensuring consistent cash flow for Garay Componentes Tubulares’ ongoing operations.

- Inheritance and Tax Strategy for High-net-worth Individual

Designed a legal structure for inheritance and asset protection to secure the economic future of a client’s family, including a comprehensive legal and tax strategy for resource allocation.

Rafael has a strong academic profile alongside his legal practice. He is a tenured professor of Income Tax in the Law Degree program at Universidad Panamericana, where he also teaches procedural aspects of amparo proceedings, as well as amparo in administrative and tax matters, within the institution’s postgraduate Specialization in Amparo Law.

In 2025, Rafael was twice invited by Universidad Panamericana’s Aguascalientes campus to teach courses as part of its Master’s Degree in Law program.

In March 2025, he was also invited by the Faculty of Law of Universidad Panamericana as a distinguished alumnus, and in September of the same year he was awarded the Alfonso X “El Sabio” Medal in recognition of more than 15 years of teaching at the institution.

Rafael has also served as director and speaker for the diploma course “El Juicio Contencioso Administrativo Federal”, organized by Tirant Formación, with the participation of magistrates and personnel from the Federal Court of Administrative Justice. Through Tirant Formación, he also taught the seminar “Juicio en la vía tradicional”.

In addition, Rafael taught the amparo proceedings module within the Diplomado de Competencia Económica, organized by the Ilustre y Nacional Colegio de Abogados de México, A.C. (INCAM), and has led modules on Administrative and Tax Amparo and Suspension of the Challenged Act as part of the Specialization in Amparo Law at the Faculty of Law of Universidad Panamericana.

Universidad Panamericana, Mexico City

Law Degree (Master)

Escuela Libre de Derecho, Mexico City

Specialization in Tax Law (Master)

Leiden University, the Netherlands

Master’s Degree in International Tax Law

Recognized for excellence in Tax: Controversy

Chambers Global 2026 Guide

2026

Ranked as a leading lawyer in Tax Controversy in Mexico

Chambers Latin America Guide 2026

2026

Ranked as a Leading Partner in Tax.

The Legal 500 Latin America 2026

2026

Recognized as "Highly Regarded" in Tax Controversy

ITR (International Tax Review) World Tax 2026

2026

Up-and-Coming Law Firm of the Year

Legal 500 Awards

2026

Tena Abogados recognized in General Corporate Tax.

ITR

2026

Tena Abogados, S.C. ranked as "Recommended" in Tax Law for both Major Tax Litigation and Corporate Tax.

Leaders League

2026

Tena Abogados, S.C. ranked as “Valuable Practice” in Corporate / M&A

Leaders League

2026

Tena Abogados, S.C. ranked as Firm to Watch

Legal 500 Latin America 2026

2026

LACCA Approved

Latin Lawyer

2026

Their client-centered approach focuses on delivering practical, tailored solutions that address the evolving needs of businesses across a wide range of sectors, including manufacturing, finance, technology, energy, and real estate..

Rafael Tena Castro specializes in Mexican law, with a strong focus on tax controversy, litigation, and corporate tax planning. However, his practice extends beyond national borders, advising international clients on cross-border tax matters and ensuring compliance with both Mexican regulations and relevant international tax frameworks.

With extensive experience navigating the complexities between domestic law and global tax standards, Rafael offers strategic solutions tailored to multinational corporations, foreign investors, and international businesses operating in Mexico. His work reflects a deep understanding of the correlation between Mexican tax law and the evolving landscape of international tax regulations.